Background
Davon R. Williams was convicted by a jury of drug and firearm offenses and sentenced to four hundred twenty months in prison by the United States District Court for the Western District of Missouri. Following the sentencing, his counsel moved to withdraw under Anders v. California, and Williams filed a pro se brief challenging his conviction and the calculation of the sentencing guidelines range.
The court’s reasoning
The court concluded that arguments based on Johnson v. United States and United States v. Davis do not apply to convictions under Section nine hundred twenty-four of Title eighteen involving drug-trafficking crimes. The court found the evidence sufficient to support the convictions and determined that the district court did not err in its jury instructions or in calculating the sentencing guidelines range. The court further held that the sentence was not substantively unreasonable and that any potential guideline error was harmless because the district court indicated it would have imposed the same sentence regardless.
What it means going forward
The judgment affirming the conviction and sentence stands, and the appointed counsel is granted leave to withdraw from the case.